3.6. Business Restructuring
| AUTHOR | |
|---|---|
| The Internal Revenue Services of the United States (IRS) | |
| lectronic document | |
| Spanish and English | |
| CIAT | October 2024 |
Contents note:
The CIAT Executive Secretariat invites you to download and read chapter “3.6. Business Restructuring” from the Manual for the Control of International Tax Planning, written by The Internal Revenue Services of the United States (IRS).
The section presents an analysis of experiences, with a focus on the United States, of types of business reorganization strategies used by multinational enterprises. These reorganize for a variety of reasons, such as expansion, aiming to reduce liability, or aligning the operating structure with the business structure, etc. Factors such as global competition, economies of scale, specialization, efficiency and cost reduction drive these reorganizations. Although tax considerations are not necessarily the main purpose for restructuring, they do influence the configuration of the new business.
Chapter 3.6. is No. 34 published within the framework of the “Manual for the Control of International Tax Planning” and is available in English and Spanish. The complete Manual consists of six sections made up of 42 chapters.